of electronically stored information Any data that is stored in an electronic form may be subject to production under common eDiscovery rules. This type of data has historically included email and office documents, but can also include photos, video, databases, and other filetypes. Also included in ediscovery is "raw data", which forensic investigators can review for hidden evidence. The original file format is known as the "native" format. Litigators may review material from ediscovery in one of several formats: printed paper, "native file", or a petrified, paper-like format, such as PDF files or TIFF images. Modern document review platforms accommodate the use of native files, and allow for them to be converted to TIFF and Bates-stamped for use in court. Electronic messages In 2006, the U.S. Supreme Court's amendments to the Federal Rules of Civil Procedure created a category for electronic records that, for the first time, explicitly named emails and instant message chats as likely records to be archived and produced when relevant. One type of preservation problem arose during the Zubulake v. UBS Warburg LLC lawsuit. Throughout the case, the plaintiff claimed that the evidence needed to prove the case existed in emails stored on UBS' own computer systems. Because the emails requested were either never found or destroyed, the court found that it was more likely that they existed than not. The court found that while the corporation's counsel directed that all potential discovery evidence, including emails, be preserved, the staff that the directive applied to did not follow through. This resulted in significant sanctions against UBS. Some archiving systems apply a unique code to each archived message or chat to establish authenticity. The systems prevent alterations to original messages, messages cannot be deleted, and the messages cannot be accessed by unauthorized persons. The formalized changes to the Federal Rules of Civil Procedure in December 2006 and in 2007 effectively forced civil litigants into a compliance mode with respect to their proper retention and management of electronically stored information (ESI). Improper management of ESI can result in a finding of spoliation of evidence and the imposition of one or more sanctions including an adverse inference jury instructions, summary judgment, monetary fines, and other sanctions. In some cases, such as Qualcomm v. Broadcom, attorneys can be brought before the bar. Databases and other structured data Structured data typically resides in databases or datasets. It is organized in tables